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May 16, 2024
He-Siang Yang
Chief Executive Officer and Chief Financial Officer
EOS INC.
5F-1, No.5, Qingdao E. Rd. Zhongzheng District
Taipei City 100008, Taiwan
Re:EOS INC.
Form 10-K for Fiscal Year Ended December 31, 2023
File No. 000-55661
Dear He-Siang Yang:
            We have reviewed your filing and have the following comments.
            Please respond to this letter within ten business days by providing the requested
information or advise us as soon as possible when you will respond. If you do not believe a
comment applies to your facts and circumstances, please tell us why in your response.
            After reviewing your response to this letter, we may have additional comments.
Form 10-K For the fiscal year ended December 31, 2023
Item 1C. Cybersecurity, page 7
1.We note you do not include Item 1.C Cybersecurity. Please revise or advise us why you
do not provide disclosure as applicable under Item 106 of Regulation S-K.
Evaluation of Disclosure Controls and Procedures, page 18
2.Please revise the heading Evaluation of Disclosure Controls and Procedures
to Management’s Report on Internal Control over Financial Reporting. In addition, you
set forth that management assessed the effectiveness of our internal control over financial
reporting as of July 31, 2018. Please correct the date in an amended filing. Lastly, you set
forth that you used the criteria set forth by the Committee of Sponsoring Organizations of
the Treadway Commission (COSO) in Internal Control - Integrated Framework. Please
revise your disclosure to refer to the specific framework used. Refer to Item 308 of
Regulation S-K.

 FirstName LastNameHe-Siang Yang
 Comapany NameEOS INC.
 May 16, 2024 Page 2
 FirstName LastName
He-Siang Yang
EOS INC.
May 16, 2024
Page 2
Item 9A. Controls and Procedures
Definition and Limitations of Disclosure Controls and Procedures, page 18
3.Please revise your heading to Evaluation of Disclosure Controls and Procedures to
provide more clarity. In addition, you refer to December 31, 2020 two times in the
paragraph, not December 31, 2023. Please correct your disclosure in an amended filing.
Refer to Item 307 of Regulation S-K.
Part IV, page 26
4.We note that both sets of certifications are dated April 16, 2023 not 2024. Please filed an
amended Form 10-K with corrected dates for your Exhibit 31 and Exhibit 32
certifications.
Consolidated Financial Statements
Accounts Receivable, page F-8
5.We note on page F-6 that you recorded $272,843 in bad debt expense in 2022 and
$148,452 in bad debt recovery in 2023, and that your bad debt expense in 2022 was
approximately 42% of net sales. Your related disclosure on pages 13, F-8 and in the
results of operations discussion does not appear to provide any information related to the
reasons these amounts were recorded. Please revise your filing to provide the disclosures
required by ASC 326-20-50-10 and 50-11, and the rollforward required by 50-13. As part
of your revised disclosure, please provide company specific details that describe the
reasons the bad debt expense and subsequent recovery were recorded. In addition, please
tell us the amount of December 31, 2023 accounts receivable that were subsequently
collected in cash and the reasons for any significant amounts that were not collected in
cash.
Revenue Recognition , page F-9
6.We note you attribute your revenue to the Asia Pacific region. Please revise your
disclosure to disclose revenues from customers attributed to your country of domicile and
attributed to all foreign countries in total from which you derive revenues. If revenues
from external customers attributed to an individual foreign country are material, those
revenues shall be disclosed separately. Refer to ASC 280-10-50-41(a).
General
7.To the extent that one or more of your officers and/or directors are located in China
or Hong Kong, please create a separate Enforceability of Civil Liabilities section for
the discussion of the enforcement risks related to civil liabilities due to your officers
and directors being located in China or Hong Kong.  Please identify each officer
and/or director located in China or Hong Kong and disclose that it will be more difficult
to enforce liabilities and enforce judgments on those individuals.  For example, revise

 FirstName LastNameHe-Siang Yang
 Comapany NameEOS INC.
 May 16, 2024 Page 3
 FirstName LastName
He-Siang Yang
EOS INC.
May 16, 2024
Page 3
to discuss more specifically the limitations on investors being able to effect service
of process and enforce civil liabilities in China, lack of reciprocity and treaties, and cost
and time constraints.
8.Please revise to provide the disclosure require by Item 101(h) of Regulation S-K,
including for example, clarifying or disclosing your:
•principal products and services and their markets, your distribution methods and the
status of any expected new products or services;
•competitive conditions, your competitive position in the industry, and in what way
you compete;
•relationships and reliance on suppliers or distributors;
•source of materials and any material suppliers; and
•material patents or intellectual property rights that you own or to which you have
acquired the rights.
In addition, please consider whether your disclosure of your number of employees should
be updated.
            We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.
            Please contact Michael Fay at 202-551-3812 or Julie Sherman at 202-551-3640 if you
have questions regarding comments on the financial statements and related matters. Please
contact Nicholas O'Leary at 202-551-4451 or Abby Adams at 202-551-6902 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Industrial Applications and
Services
cc:       Brett Verona, Esq.